1 Title 13 California Air Resources  Board  
Notice  of Public  Hearing  to Consider  Proposed  Zero-
Emission  Forklift  Regulation  
The California Air Resources  Board  (CARB  or Board)  will conduct  a public hearing  at the date 
and time noted  below  to consider  the proposed  Zero-Emission  Forklift Regulation (Proposed  
Regulation) . 
Date:  June 27, 2024 
Time: 9:00 A.M.  
In-Person  Location: 
Mary  D. Nichols Campus,  Southern California Headquarters  
California Air Resources  Board  | Haagen -Smit Auditorium 
4001 Iowa  Avenue,  Riverside, California 92507  
Remote  Option:  
Zoom 
This public meeting may continue at 9:00 a.m ., on June 28, 2024. Please consult the public 
agenda, w hich will be posted te n days before th e June 27, 2024 Board Meeting, for 
important details, including, but not limited to, the day on which this  item will be considered, 
how to participate via Zoom, and any appropriate direction regarding a possible  remote -only 
Board Meeting if needed. 
Written Comment Period and Su bmittal of Comments 
In accordance with  the Administrative Procedure Act, interested members of the public may 
present comm ents orally o r in writing during the hearing and may p rovide comments by 
postal mail or by electronic  submittal before the hearing. The public c omment period for this  
regulatory action w ill begin  on Novembe r 10, 2023. Written comments not submitted during 
the hearing must be submitted on o r after November 10 , 2023, and rec eived no later than  
December 26, 2023. Comments submitted outside that comment period are considered 
untimely. CARB may, but is not required to, respond to untimely c omments, including those 
raising significant environmental issues. The Board also encourages members of the public to 
bring  to the attention of staff in advance  of the hearing any suggestions fo r modification of 
the proposed regulatory action. Comments submitted in advance of  the hearing  must be 
addressed to one of the following:  
P
ostal  mail: Clerks’ Office,  California  Air Resources  Board  
1001 I Street,  Sacramento,  California 95814  
Electronic submittal :  https://www.arb.ca.gov/lispub/comm/bclist.php  2Please  note that under  the California  Public  Records Act (Gov.  Code,  § 6250  et seq.),  your 
written  and oral comments,  attachments,  and associated  contact  information  (e.g.,  your 
address,  phone,  email,  etc.) become  part of the public  record  and can be released to the 
public  upon  request.
Additionally,  the Board  requests  but does  not require  that persons  who submit  written  
comments to the Board  reference  the title of the proposal  in their comments to facilitate  
review.
Authority and Reference
This regulatory  action  is proposed  under  the authority  granted in California  Health  and Safety  
Code,  sections  39600,  39601,  43013,  43018,  43101,  43102,  and 43104 . This action  is 
proposed  to implement,  interpret,  and make  specific  sections  43013,  43017,  43018,  43101,  
43102,  43104,  43105,  43150,  43151,  43152,  43153,  43154,  43205.5,  43211,  and 43212 .
Informative Digest of Proposed Action and Policy Statement 
Overview (Gov. Code, § 11346.5, subd. (a)(3))
Sections  Affected:
CA
RB proposes  to modify  section s 24
33 and 2775 .1 of the California  Code  of Regulations  
(CCR) , title 13 and add to the CCR, title 13, the following  sections:  3000,  3001,  3002,  3003,  
3004,  3005,  3006,  3007,  3008 , 3009,  3010,  and 3011 .
Documents  Incorporated  by Reference  (Cal. Code  Regs.,  tit. 1, § 20, 
subd.  (c)(3)):
T
he following  documents,  test methods,  and model  would  be incorporated  in the regulation  
by reference  as specified by s
ection :
·American  National  Standard  Institute,  “Safety  Standard  for Rough  Terrain  Forklift  Trucks”,  
2021,  ANSI  B56.6 -2021 , incorporated  by reference  in CCR, title 13, section  3000.
·American  National  Standard  Institute,  “Safety  Standard  for Vehicle  Mounted  Forklifts”,  
2020 , ANSI  B56.14 -2020,  incorporated  by reference  in CCR, title 13, section  3000.
·Title 29, Code  of Federal  Regulations,  Part 1910.147(b) , last amended on July 25, 2011,  
incorporated  by reference  in CCR title 12, section  3000.
Background  and Effect of the Proposed  Regulatory  Action:
C
ARB mobile  source  programs  have  m
ade significant  progress  in improving  air quality  
throughout  California.  However,  many  areas  throughout  the State  still fail to attain  the 
National  Ambient  Air Quality  Standards  (NAAQS)  for ozone  and fine particulate  matter  (PM) 
(i.e., PM2.5).  About  26 million  Californians  live in areas  exceeding  the NAAQS,  out of th
e 
total population  of about 39 million.  Consequently,  about 67 percent  of California's  
population  live in areas  exposed to concentrations  above  the federal  ozone  and PM2.53standards1. In addition,  climate  change  continues  to impact  California  communities  and the 
environment  by increasing  smog  formation2,3,4; extending  the pollen  season;  contributing  to 
intense  wildfires5; creating  hotter  temperatures  that could  cause  heat-related  health  
problems6,7; cause  weather  extremes,  such as drought8and flooding9,10; and increase  
prevalence  of infectious  diseases11,12. Taking  action  to reduce  criteria -pollutant  and 
greenhouse  gas (GHG ) emissions  is urgently  needed  to reduce  the toll air pollution  and 
climate  change  is taking  on Californians.
Mobile  sources  and the fossil  fuels  that power  them  are the largest  contributors  to the 
formation  of ozone,  GHG  emissions,  fine PM (i.e., PM2.5),  and toxic  diesel  PM. The 
combustion  of fossil  fuel by mobile  sources  accounts  for approximately  80 percent  of  
smog -forming  nitrogen  oxide  (NOx)  emissions,  90 percent  of the diesel  PM emissions,  and
1Based  on 2021 monitored  ozone  design  values  contoured  over population  by census  tract
2Reidmiller,  D.R.,  et al., Impacts,  Risks,  and Adaptation  in the United  States:  Fourth  National  Climate  
Assessment,  Volume  II, Chapter  14, Human  Health,  U.S. Global  Change  Research  Program,  2018  (web  link:
https://nca2018.globalchange.gov/chapter/14/ ).
3McMichael , A.J. et al. (Eds.) , Climate  Change  and Human  Health:  Risks and Responses,  World  Health  
Organization,  page  12, 2003  (web  link:https://apps.who.int/iris/bitstream/handle/10665/42742/  
924156248X_eng.pdf?sequence=1&isAllowed=y ).
4NRDC,  Issue  Brief:  Climate  Change  and Health  in California,  page  3, February  2019  (web  link:
https://www.nrdc.org/sites/default/files/climate -change -health -impacts -california -ib.pdf ).
5Singleton , M.P. et al., Increasing  Trends  in High-Severity  Fire in the Southwestern  USA from  1984  to 2015 , 
Forest  Ecology  and Management,  Volume  433, 2019 (web  link:
https://www.fs.usda.gov/rm/pubs_journals/2019/rmrs_2019_singleton_m001.pdf ).
6Kadir , T. et. al (Eds.) , Indicators  of Climate  Change  in California,  Office  of Environmental  Health  Hazard  
Assessment , August  2013  (web  link:https://oehha.ca.gov/media/downloads/climate -
change/document/climatechangeindicatorsreport2013.pdf ).
7California  Air Resources  Board , Health  & Air Pollution  (web  link: https://ww2.arb.ca.gov/resources/health -air-
pollution , last accessed  August  2023 ).
8Mann,  M.E. and Gleick,  P.H.,  Climate  Change  and California  Drought  in the 21st Century,  Proceedings  of the 
National  Academy  of Sciences  of the United  States  of America , March  2015  (web  link:
https://www.pnas.org/doi/epdf/10.1073/pnas.1503667112 ).
9Swain , D.L. et al., Increasing  Precipitation  Volatility  in Twenty -First-Century  California,  Nature,  2018  (web  link:
https://www.sierraforestlegacy.org/Resources/Conservation/FireForestEcology/ThreatsForestHealth/Climate/CI
_Swain_etal_2018_Increasing_Precip_Volatility.pdf ).
10Dettinger,  M., Climate  Change,  Atmospheric  Rivers,  and Floods  in California —a Multimodel  Analysis  of Storm  
Frequency  and Magnitude  Changes,  Journal  of the American  Water  Resources  Association,  June  2011  (web  
link: https://ca.water.usgs.gov/pubs/2011/climate -change -atmospheric -rivers -floods -california -dettinger.pdf ).
11Lindgren , E. et al., Monitoring  EU Emerging  Infectious  Disease  Risk Due to Climate  Change,  Science , April  
2012  (web link:
https://www.researchgate.net/publication/224856024_Monitoring_EU_Emerging_Infectious_Disease_Risk_Due_
to_Climate_Change).
12Solomon , G. et al., Airborne  Mold and Endotoxin  Concentrations  in New  Orleans,  Louisiana,  After Flooding,  
October  through  November  2005,  Environmental  Health  Perspectives , September  2006  (web  link:
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1570051/ ).4nearly  40 percent  of statewide  GHG  emissions.131415Of that, off-road equipment  contributes  
to approximately  14 percent  of the NOx  emissions  and seven  percent  of the PM emissions  
attributable to mobile  sources.16
The Proposed  Regulation  has been  identified  in the 2016  State  Strategy  for the State  
Implementation Plan,  the 2016  Mobile  Source  Strategy  (MSS),  the 2020  MSS,  and the 
Sustainable  Freight  Action  Plan as one of several  measures  necessary  for California  to achieve  
its established air-quality  and climate  goals.
Forklifts  that use internal  combustion  engines  can be spark -ignited  (i.e., gasoline,  propane,  or 
natural  gas) or compression -ignited  (i.e., diesel).  Large  Spark -Ignition  (LSI) forklifts  are  
spark -ignited  forklifts  of 25 horsepower  or greater.
The Proposed  Regulation  would  reduce  criteria -pollutant  and GHG  emissions  within  the State  
by accelerating  the transition  of LSI engine  powered  forklifts  to zero-emission  technology  
(i.e., battery -electric,  fuel cell-electric,  or other  zero-emission  technology  as the only source  
of power  for propulsion  and work).  Certain  types  of forklifts,  such as rough -terrain  forklifts  
and diesel forklifts , would  not be addressed by the Proposed  Regulation.
About  half of the forklift  population  in California  already uses zero-emission  technology  
largely  due to advantages  that zero-emission  technology  can provide,  such as reduced 
indoor  air pollution  and lower  operating  costs.  The Proposed  Regulation  would  target  most  
existing  LSI forklifts  for use of zero-emission  technology.
CARB  may also consider  other  changes  to the sections  affected,  as listed  on page  2 of this 
notice, or other  sections  within  the scope  of this notice, during  the course  of this rulemaking 
process.
Objectives  and Benefits  of the Proposed Regulatory  Action:
The primary  objectives  of the Proposed  Regulation  include  the following:
·Accelerate  the deployment  of Zero-Emission  Forklifts  (ZEFs), which  achieve  the 
maximum  emissions  reduction  possible  to assist  in the attainment of NAAQS  for 
criteria  air pollutants  (Health  & Safety  Code  Sections  43000.5(b)  and 43018(a)) .
·Decrease  and eliminate  emissions  from  petroleum  and fossil -fuel use by forklifts  by  
setting standards  that eliminate  exhaust emissions  from  forklifts.  Emissions  from  
petroleum  use as an energy  resource  contribute substantially  to the following  public
13California  Air Resources  Board , 2022  Scoping  Plan for Achieving Carbon  Neutrality , page  184, December  
2022  (web link: https://ww2.arb.ca.gov/sites/default/files/2023 -04/2022 -sp.pdf ).
14California  Air Resources  Board , Mobile  Source  Strategy , page  5, May 2016  (web  link:
https://ww3.arb.ca.gov/planning/sip/2016sip/2016mobsrc.pdf ).
15California  Air Resources  Board , 2022  Scoping  Plan for Achieving Carbon  Neutrality , page  56, Figure  1-8: 2019  
State  GHG  emission  contributions  by Scoping  Plan sector , December  2022  (web link:
https://ww2.arb.ca.gov/sites/default/files/2023 -04/2022 -sp.pdf ).
16California  Air Resources  Board , Staff Report  for the Proposed  Amendments  to the In-Use Off-Road  Diesel -
Fueled  Fleets  Regulation,  page  35, September  2022  (web  link: https://ww2.arb.ca.gov/sites/default/  
files/barcu/regact/2022/off -roaddiesel/isor.pdf ).5health  and environmental  problems,  among  others:  air pollution  and its associated  
health  impacts,  acid rain, global  warming,  and the degradation  of California’s  marine  
environment  and fisheries  (PRC  Section  25000.5[b],  [c]).
·Decrease  GHG  emissions  in support  of statewide  GHG  reduction  goals  by adopting  
strategies  to deploy  ZEFs  in California  to support  the Scoping  Plan,  which  was 
developed  to reduce  GHG  emissions  in California,  as directed  by Assembly  Bill (AB) 32 
(Nu?ez,  Chapter  488, Statutes  of 2006 ) and Executive  Order  S-3-05 (Ch. 249, Stats.  
2016,  Pavley) .
·Develop  a regulation  that is consistent  with and meets  the goals  of the State  
Implementation  Plan (SIP),  providing  necessary  emissions  reductions  for all of 
California’s  nonattainment  areas  to meet  NAAQS  (Health  & Safety  Code  Sections  
39002,  39003,  39602.5,  43000,  43000.5,  43013,  and 43018) .
·Maintain  and continue  reductions  in emissions  of GHGs  beyond  2020,  in accordance  
with Senate  Bill (SB) 32 (Health  & Safety  Code  Sections  38551(b),  38562,  38562.5,  
38566 ); and pursue  measures  that implement  reduction  strategies  covering  the State’s  
GHG  emissions  in furtherance  of California’s  mandate  to reduce  GHG  emissions  to the 
1990  level by 2020  and 40 percent  below  the 1990  level by December  31, 2030 . In 
addition,  target  and achieve  carbon  neutrality  in California  as soon  as possible , but no 
later than 2045,  pursuant  to SB 100 (De León , Chapter  312, Statutes of 2018)  and AB 
1279  (Muratsuchi,  Chapter  337, Statutes  of 2022 ), maintain  net negative  emissions  
thereafter  in accordance  with AB 1279  and Executive  Order  B-55-18, and to ensure  
that by 2045,  statewide  anthropogenic  greenhouse  gas emissions  are reduced  to at 
least  85 percent  below  the 1990  levels,  pursuant  to AB 1279 .
·Lead  the transition  of California’s  off-road sector  from  internal  combustion  to  
zero-emission  technology.  Support  ZEF sales  and Executive  Order  N-79-20’s goal to 
transition  off-road operations  to zero-emission  by 2035.
·Complement  existing  programs  and plans  to ensure,  to the extent  feasible,  that 
activities  undertaken  pursuant  to the measures  complement,  and do not interfere  with,  
existing  planning  efforts  to reduce  GHG  emissions,  criteria  pollutants,   
petroleum -based  transportation  fuels,  and toxic  air contaminant  emissions.
·Incentivize  and support  emerging  zero-emission  technology  that will be needed  to 
achieve  CARB’s  SIP goals.
·Achieve  emission  reductions  that are real, permanent,  quantifiable,  verifiable,  and 
enforceable  (Health  & Safety  Code  Sections  38560,  38562(d)(1)).
·Provide  market  certainty  for zero-emission  technologies  and charging  and  
hydrogen -fueling  infrastructure  to guide  the acceleration  of the development  of 
environmentally  superior  ZEFs  that will continue  to deliver  performance,  utility,  and 
safety  demanded  by the market.
·Take  steps  to ensure  all Californians  can live, work,  and play in a healthful  environment  
free from  harmful  exposure  to air pollution.  Protect  and preserve  public  health  and6well-being,  and prevent  irritation  to the senses,  interference  with visibility,  and 
damage  to vegetation  and property  (Health  & Safety  Code  Section  43000(b)).
·Spur economic  activity  of zero-emission  technologies  in the off-road sectors.  
Incentivize  innovation  that will transition  California’s  economy  into greater  use of clean  
and sustainable  zero-emission  technologies  and promote  increased  economic  and 
employment  benefits  that will accompany  this transition  (AB 1493,  Section  1(g) 
(Pavley,  Chapter  200, Statutes  of 2002) ; Health  & Safety  Code  Section  38501(e)).
·Establish  a fair and level playing  field among  fleet operators , forklift  manufacturers,  
forklift  dealers,  and forklift  rental  agencies.
·Craft  requirements  in a way that ensures  institutional  capacity  for CARB  to manage,  
implement,  and enforce  requirements.
The Proposed  Regulation  is one of many  regulatory  measures  that will be needed  to achieve  
California’s  air-quality,  climate,  and zero-emission  goals.  The Proposed  Regulation  would  
establish  phase -out requirements  applicable  to the most -common  internal -combustion  
forklifts  used  in industrial  and other  applications  across  the State.  Given  operational  
constraints  (such  as indoor  operation  and forklift  size) and the state  of zero-emission  forklift  
technology,  phased -out LSI forklifts  are expected  to be ultimately  replaced  with  
zero-emission  forklifts  (battery -electric  or fuel-cell powered).
Full implementation of the Proposed Regulation  through calendar year 2043 is expected  to 
result in the following emission reductions :
·18,724 tons of NOx .
·2,075 tons of PM2.5 .
·4,973  tons of reactive organic gases ( ROG ).
·9.4 million metric tons ( MMT ) of carbon dioxide ( CO 2).
Estimated cumulative health impacts of the Proposed Regulation through calendar year 2043 
include the following:
·544 avoided cardiopulmonary mortalities.
·115 fewer hospital admissions for cardiovascular disease.
·148 fewer cases of cardiovascular Emergency Department visits.
·62 fewer cases of nonfatal acute myocardial infarction.
·17 fewer hospitalizations for respiratory disease.
·321 fewer cases of respiratory Emergency Department visits.
·42 fewer cases of lung cancer incidence.
·1,295 fewer cases of asthma onset.
·109,800 fewer cases of asthma symptoms.
·80,635 fewer cases of work loss days.
·272 fewer hospitalizations for Alzheimer’s disease.
·39 fewer hospitalizations for Parkinson’s disease.
Cumulative cost -savings  from full implementation of the Proposed Regulation  through 
calendar year 2043 are estimated as follows :7·$7.5 billion in health benefit savings.
·$0.25 to $1 billion in social cost of carbon savings.
·$2.7 billion in net fleet cost saving s.
Without the Proposed Regulation, the ZEF population is expected to remain somewhat 
constant, at a population of about 79,000. The Proposed Regulation is projected to 
significantly increase the number of ZEFs  in California. The estimated number of ZEFs would 
increase from about 79,000  to about 109 ,000 in 203 1, and to abo ut 168,000 ZE Fs by 20 38, 
when full implementation  would be reached. 
Summary  of Proposed  Regulation
The Proposed Regulation would require California fleets to phase out most LSI forklifts over 
time. The Proposed Regulation includes two primary components: a restriction on the sale 
and acquisition of LSI forklift s starting on January 1, 2026, and phase -out requirements 
starting on January 1, 2028, for existing LSI forklift s. The Proposed Regulation would also 
establish requirements for forklift manufacturers, forklift dealers, and forklift rental agencies. 
The following bullets provide more detailed information on each component of the Proposed 
Regulation.
A.Scope  
· Applicable  forklift s would  fall into two categories,  Class  IV and Class  V, based  on the 
powered  industrial  truck  classification  system  developed  by the Occupational  Safety  
and Health  Administration17.
o A Class  IV forklift  is one that uses an internal -combustion  engine,  has cushion  
tires,  and is typically  used indoors  on smooth  surfaces.
o A Class  V forklift  is one that uses an internal -combustion  engine,  has 
pneumatic  tires (air-filled,  foam- filled,  or solid),  and is typically  used outdoors  
on uneven  surfaces.
·The Proposed  Regulation  would  apply  to Class  IV and Class  V forklifts  that use LSI 
engines  (hereinafter  “Class  IV LSI Forklifts”  and “Class  V LSI Forklifts,”  respectively).  
However,  certain  types  of forklifts,  such as rough  terrain  forklifts,  vehicle  mounted 
forklifts,  diesel forklifts,  combat  and tactical  support  equipment,  and others  would  be 
excluded  from  the Proposed  Regulation.
·The performance requirements of the Proposed  Regulation  (i.e., purchase  restriction 
and phase -out requirements)  would  apply  to Class  IV LSI Forklifts  of any lift capacity  
and Class  V LSI Forklifts  with a lift capacity  of up to 12,000  pounds  (hereinafter 
“Targeted Class  IV forklifts”  and “Targeted Class  V forklifts,”  respectively,  and
17Occupational  Safety  and Health  Administration,  Powered Industrial  Trucks  (Forklift)  eTool (web  link:
https://www.osha.gov/etools/powered -industrial -trucks/types -fundamentals/types/classes , last accessed  August  
2023).8collectively as “Targeted Forklifts”). Although  the performance requirements  of t he 
Proposed  Regulation  would not apply to Class  V LSI Forklifts with a lift capacity  
greater  than 12,000  pounds,  reporting  of said forklifts would be required.
B.Forklift  Fleet  Operators  
· Beginning  on January  1, 2026,  fleets  would not be allowed  to acquire  or take 
possession  of a new Target ed Forklift.
·Beginning  on January  1, 2026,  fleets  would not be allowed  to acquire  or take 
possession  of a used  2026  or subsequent model year (M Y) Targeted  Forklift.
·MY Phase -Out Schedule:  Beginning  January  1, 2028,  Targeted  Forklifts  in operation  
prior  to January  1, 2026,  would  be required  to be phased  out of the California  fleet in 
accordance  with the MY schedule  that is summarized as follows:
o Class  IV LSI forklifts with a lift capacity  of 12,000  pounds  or less: 
· For Large Fleets  (26 or more  forklifts), phase -out would begin on 
January  1, 2028 , starting with 2018  and previous  MY forklifts, and end 
on January  1, 2035 , by which 2025  MY forklifts would be required  to be 
phased  out.
· For Small Fleets  (less than 26 forklifts) and Agricultural  Operations , 
phase -out would begin  on January  1, 2029 , starting  with 2016  and 
previous  MY forklifts, and end on January  1, 2038 , by which 2025  and 
previous  MY forklifts would be required  to be phased  out.
o Class  IV LSI forklifts with a lift capacity  of more  than 12,000  pounds  
· For Large Fleets,  phase -out of 2025  and previous  MY forklifts would  be 
required  to occur  by January  1, 2035.
· For Small Fleets  and Agricultur al Operations,  phase -out of 2025  and 
previous  MY forklifts would be required  to occur  by January  1, 2038.
o Class  V LSI forklifts with a lift capacity  of 12,000  pounds  or less 
· For all fleets,  phase -out would begin on January  1, 2030 , starting  with 
2017  and previous MY forklifts, and end on January  1, 2038 , by which  
2025 MY forklifts would  be required  to be phased  out. 
·F
orklift fleets  would be expected  to replace phased -out Targeted  Forklifts with ZEFs,  
either  battery -electric  or fuel-cell electric.
·Until January  1, 2038,  forklift fleets  would still be able to purchase,  lease,  or rent used 
202
5 and previous MY Targeted  Forklifts for use in California so long  as said forklifts 
have  not yet been  phased out according  to the applicable MY Phase -Out Schedule  
summarized  above .9·Until January  1, 2038,  forklift fleets  would be able to rent 2026,  2027,  and 2028  MY 
Targeted  Class  V Forklifts  for use in California.
·The Proposed  Regulation  would include  compliance  exemptions  for low usage,  
emergency  operations,  and temporary  storage  of Targeted  Forklifts to be removed  
from  the fleet as well as compliance  extensions  for infrastructure  construction,  ZEF 
delivery  delays, and feasibility issues.
·The Proposed  Regulation  would allow a Fleet  Operator  to delay the phase -out of one 
Targeted  Forklift until January  1, 2038,  for each  Class  V LSI Forklift with a lift capacity  
greater  than 12,000  pounds  replaced  with an equivalent ZEF.
·The Proposed  Regulation  includes  annual  reporting  and recordkeeping  requirements 
starting  January  1, 2026,  and labeling requirements in certain  situations.
·Staff’s proposal  includes  amendments  to existing  reporting  and labeling requirements  
in the LSI Engine Fleet  Requirements  Regulation  (LSI Fleet  Regulation),  set forth  in 
Title 13, California Code  of Regulations,  Sections  2775,  2775.1,  and 2775.2.  T he  
revisions  would simplify that regulation’s  reporting requirements , which would reduce  
the compliance  burden for operators  as well as increase  clarity  of the annual  reporting  
requirements,  since  many of t he  operators  that would be subject to the Proposed  
Regulation  are currently  subject  to the LSI Fleet  Regulation.
·Beginning  January  1, 2026,  a commercial  or governmental  entity  that hires a Fleet  
Operator  would also be responsible  for the operation  of an LSI Forklift  that does  not 
comply  with the provisions  in the Proposed  Regulation.
C.Forklift  Manufacturers 
· The Proposed  Regulation  would establish  a new zero-emission  standard for engines  
and powertrains  used in zero-emission  forklifts.
·Manufacturers  would no longer  be allowed  to produce  for sale in California or offer  
for sale in California new Targeted  Class  IV Forklifts as of January  1, 2026,  and no 
longer  be allowed  to produce  for sale in California or offer  for sale in California new 
Targeted  Class  V Forklifts  January 1, 2029,  unless  the forklift  engine  meets  the 
zero-emission  standards  set forth  by the Proposed  Regulation.
·Beginning  January  1, 2026,  manufacturers  would be required  to submit  production  
and sales information  to the Executive  Officer  annually for all LSI forklifts produced  
for sale or sold in California.
D.Forklift  Dealers  
· A dealer would not be allowed  to possess  the following:  
o 2026  and subsequent MY Targeted  Class  IV Forklifts starting  January  1, 2026;10o New Targeted  Class  IV Forklifts  starting  January  1, 2026;
o 2025  and previous  MY Targeted  Class  IV Forklifts  that have  already  been  
phased  out in accordance  with the phase -out schedule  for Class  IV LSI Forklifts  
in Small  Fleets  and Agricultural  Operations,  summarized  above , starting  
January  1, 2026;
o 2025  or previous  MY Targeted  Class  V Forklifts  that have  already  been  phased  
out in accordance  with the Class  V LSI Forklift  phase -out schedule  summarized  
above , starting  January  1, 2026;
o 2026  and subsequent  MY Targeted  Class  V Forklifts  starting  January  1, 2029;  
and
o Any Targeted  Forklift  starting  January  1, 2038.
·Starting  January  1, 2026,  a dealer  would  not be able sell, lease , offer  for sale, offer  for 
lease,  or deliver  to a fleet operator  in California:
o A new Targeted  Forklift .
o A used  2026  or subsequent  MY Targeted  Forklift .
o A 2025  or previous  MY Targeted  Forklift  if the MY of said forklift  has already  
been  phased  out in accordance  with the applicable  schedule  summarized  
above.  For Targeted  Class  IV Forklifts,  a dealer  would  use the phase -out 
schedule  for Small  Fleets  and Agricultural  Operations  to determine  whether  or 
not a Forklift  has been  phased  out.
·Starting  January  1, 2026 , a dealer  would  not be able to sell, lease , offer  for sale, offer  
for lease,  or deliver  to a rental  agency  in California:
o A new Targeted  Class  IV Forklift.
o A used  2026  or subsequent  MY Targeted  Class  IV Forklift.
o A 2025  or previous  MY Targeted  Class  IV Forklift  if the MY of said forklift  has 
already  been  phased  out in accordance  with the applicable  schedule  for Class  
IV Forklifts  in Small  Fleets  and Agricultural  Operations,  as summarized  above .
o A 2025  or previous  MY Targeted  Class  V Forklift  if the MY of said forklift  has 
already  been  phased  out in accordance  with the Class  V Forklift  phase -out 
schedule  summarized  above.
·Starting  January  1, 2029,  a dealer  would  not be able to sell, lease , offer  for sale, offer  
for lease,  or deliver  to a rental  agency  in California:
o A new Targeted  Class  V Forklift.
o A used  2026  or subsequent  MY Targeted  Class  V Forklift.11·The Proposed  Regulation  would include  exemptions  for dealers  to sell and transport  
new Targeted  Forklifts to out-of-state  purchasers  and to fleet o perators t hat would 
operate  such forklifts as dedicated  emergency  forklifts.
·The Proposed  Regulation  includes  recordkeeping  requirements on LSI forklift sales 
transactions  starting  January 1 , 2026.
E.Forklift  Rental  Agencies  
· Rental a gencies  would be subject  to the same  MY phase -out schedule  as fleet 
operators.
·Unlike fleet o perators,  between  January  1, 2026,  and December  31, 2028,  rental 
agencies  would be allowed  to acquire  Targeted  Class  V Forklifts as forklifts they offer  
for rent.  Such  forklifts would be required  to be phased  out by January 1, 2038.
·The Proposed  Regulation  would allow a rental a gency  to delay the phase -out of one 
Targeted  Forklift until January  1, 2038,  for each  Class  V LSI Forklift with a lift capacity  
greater  than 12,000  pounds  replaced with an equivalent Z EF.
·The Proposed  Regulation  includes  annual  reporting  and recordkeeping  requirements 
s
tarting  January  1, 2026.
Comparable  Federal  Regulations:
The SIP acknowledges  the need for emission  reductions  in the off-road vehicle  sector  and has 
included  the Proposed  Regulation  as one of the measures  that will support  meeting the air 
quality  standards  established in the federal  Clean  Air Act (CAA) .18
There  are currently  no federal  requirements for fleets  or rental  agencies  to phase out the 
purchase  or use of Targeted  LSI forklifts. There  are also no federal  requirements  prohibiting 
manufacturers  or dealers  from  selling T argeted  LSI forklifts.
An Evaluation  of Inconsistency  or Incompatibility  with Existing  State 
Regulations  (Gov.  Code,  § 11346.5,  subd.  (a)(3)(D)):
During  the process  of developing  the proposed  regulatory  action, C ARB  conducted  a search  
of any similar regulations  on this topic  and concluded  these  regulations  are neither  
inconsistent  nor incompatible with e xisting  state  regulations.
18The federal  Clean Air Act sets out requirements  for adoption  of air quality  standards,  as well as the required 
elements  of State Implementation  Plan s, which must demonstrate  how a nonattainment  area will meet  the 
standards  by the required  attainment  deadline.12Disclosure Regarding the Proposed Regulation
Fiscal  Impact/Local  Mandate  Determination  Regarding  the Proposed  
Action (Gov.  Code,  § 11346.5,  subds.  (a)(5)&(6)):
The determinations  of the Board's  Executive  Officer  concerning  the costs  or savings  incurred  
by public  agencies  and private  persons  and businesses  in reasonable  compliance  with the 
proposed  regulatory  action  are presented below.
Under  Government Code  sections  11346.5,  subdivision  (a)(5)  and 11346.5,  subdivision  (a)(6),  
the Executive  Officer  has determined that the proposed  regulatory  action  would  create  costs  
or savings  to any State  agency,  would  not create  costs  or savings  in federal  funding  to the 
State,  and would  create  costs  or mandate  to any local agency  or school  district,  whether or 
not reimbursable  by the State  under  Government  Code,  title 2, division  4, part 7 
(commencing  with section  17500),  or other  nondiscretionary  cost or savings  to State  or local 
agencies.
Cost to any Local  Agency  or School  District  Requiring  Reimbursement  under  section  17500  
et seq.:
Pursuant to Government  Code  sections  11346.5,  subdivision  (a)(5)  and 11346.5,  
subdivision  (a)(6),  this regulatory  action  will result  in a mandate  that would  create  costs  and 
cost-savings  to local agencies  and school  districts.  However,  these  costs  are not reimbursable 
by the State  pursuant  to Government Code,  title 2, division  4, part 7 (commencing  with 
section  17500),  because  this action  neither compels  local agencies  to provide new 
governmental  functions  (i.e., it does  not require  such agencies  to provide additional  services  
to the public),  nor imposes  requirements  that apply  only on local agencies  or school  
districts19. Instead,  this regulatory  action  establishes  requirements  that would  apply  to all 
individuals  and entities  that own or operate  regulated forklifts.  This action  also does  not 
compel  local agencies  to increase  the actual  level or quality  of services  that they already 
provide the public20. For the foregoing  reasons,  any costs  incurred  by local agencies  to 
comply  with this regulatory  action  are not reimbursable21.
Cost or Savings  for State  Agencies:
To implement the Proposed Regulation , CARB would need permanent staffing resources. 
This would be met through a combination of new staffing resources and redirecting existing 
staffing resources. In addition to staffing needs, the Proposed Regulation  would require 
modifying and upgrading existing reporting systems. 
State  government  is assumed  to incur  an incremental  cost from  the purchase  of ZEFs,  while  
also realizing  operational savings  from  the use of ZEFs.  State  and local government  fleets  are 
estimated  to make  up about 3 percent  of the California’s  affected  forklift  fleet.  Assuming the 
number of forklifts owned by State and local governments is proportional to their share of 
19County  of Los Angeles  v. State  of California  (1987)  43 Cal.3d  46, 56.
20San Diego  Unified  School  Dist. v. Commission  on State  Mandates  (2004)  33 Cal.4th  859, 877.
21County  of Los Angeles  v. State  of California,  43 Cal.3d. 46, 58.13government employment, it is estimated that 2.2 percent and 0.8 percent of the statewide 
forklift cost and operational savings resulting from the Proposed Regulation would be 
realized by local government fleets and State government fleets, respectively.22
Annual  net total fiscal  impact  to the State  government  is estimated  to range  between  a net 
positive  budgetary  impact  of $7.2 million  in 2030 , primarily  due to increased  sales  tax 
revenue,  to a net negative  budgetary  impact  of $49.3 million  in 2040.  Through  2043,  the 
cumulative  total upfront  cost to the State  government  is estimated  to be $32.8 million,  and 
the cumulative  total fiscal  impact  is estimated  to be a net negative  budgetary  impact  of 
$159.7 million  from  2024  through  2043.  A negative  net budgetary or fiscal impact results 
when revenue losses and costs exceed revenue gains and cost savings.
Other  Non-Discretionary  Costs  or Savings  on Local  Agencies:
Local government  fleets are estimated  to make  up roughly  2.2 percent  of California’s  fleet.  
All local government  fleets  are subject  to the Proposed  Regulation  with requirements 
beginning for most  fleets  in 2026.
Upfront costs would include the cost of purchasing new ZEFs as well as infrastructure costs 
for adding forklift battery chargers, facility improvements, and electrical upgrades. Local 
governments would also be expected to realize cost savings related to re duced ZEF energy 
cost, lower ZEF maintenance cost, and revenue from Low Carbon Fuel Standard ( LCFS ) 
credits . In addition, local governments would be impacted by reduced gasoline and use taxes 
due to reduced usage of gasoline and propane, respectively, and increased sales taxes due 
to the sale of ZEFs and associated equipment and utility user fees.
Accounting for both total upfront costs and total operational costs results in total costs of 
$157.9 million for local governments from 2026 through 2043. Over that same period, staff 
estimates total cost -savings of $220.2 million due to operational saving s. In terms of tax and 
fee revenue, the Proposed Regulation would result in increases in Utility User fees revenue 
and sales tax revenue totaling $167.0 million and in decreases in gasoline tax revenue and 
use tax revenue totaling $398.1 million. Accountin g for all costs and savings, the total fiscal 
impact is estimated to be a net negative budgetary impact  (i.e., a cost) of $168.9 million from 
2026 through 2043 .
Cost or Savings  in Federal  Funding to the State:
The Proposed  Regulation  is not expected  to impose  any costs  or savings  in federal  funding  
to the State.
Housing  Costs  (Gov. Code,  § 11346.5,  subd.  (a)(12)):
The Executive  Officer  has also made  the initial  determination that the proposed  regulatory  
action  will not have  a significant  effect  on housing  costs.
22Based on REMI  Policy  Insight  Plus (v3.0.0),  Local  governments’  share  of State  and Local  government  
employment  is 77 percent.14Significant  Statewide  Adverse  Economic  Impact  Directly  Affecting  
Business,  Including  Ability  to Compete  (Gov.  Code,  §§ 11346.3, 
subd.  (a), 11346.5, subd.  (a)(7),  11346.5, subd.  (a)(8)):
The Executive  Officer  has made  an initial  determination that the proposed  regulatory  action  
would  not have a significant  statewide  adverse  economic  impact  directly  affecting  
businesses,  including  the ability  of California  businesses  to compete with businesses  in other  
states,  or on representative  private  persons.  In addition,  as discussed  further below,  the 
Proposed  Regulation  would  apply  equally  to all fleets  operating  forklifts  in California  whether 
they are California  businesses  or out-of-state  businesses.  Furthermore,  forklifts  are not 
generally  transported  from  one state  to another in order  to perform  work,  so staff does not 
expect  that California  forklift  fleets  are competing  for work  with out-of-state  forklift  fleets.  
Finally,  although  the proposed  forklift  requirements  could  make  it more  expensive  in the very 
short  term  to operate  in California  (due to the capital  needed to purchase  ZEFs),  the 
Proposed  Regulation  is projected  to result  in overall  net savings  for fleets  within  the state.
Results of The Economic Impact Analysis/Assessment (Gov. Code, 
§ 11346.5, subd.  (a)(10)): 
Major  Regulation:  Statement  of the Results  of the Standardized  
Regulatory  Impact  Analysis  (SRIA)  (Gov.  Code,  § 11346.3,  subd.  (c)):
In Ap
ril 2023 , CARB  submitted  a Standardized Regulation  Impact  Assessment (SRIA)  to the 
Department  of Finance  (DOF) for its review. CARB  has updated  the Proposed  Regulation  
since  th
e original  SRIA  submittal  and addressed  DOF  comments on the SRIA . Details  are 
provided  in Appendix  B of the I SOR .
(A) The creation  or elimination of jobs within  the state.  
The Proposed  Regulation  is estimated  to result  in an initial decrease  in employment  growth  
that is less than 0.01 percent  of baseline  employment  and begins to diminish  towards the 
end of the regulatory  horizon.  The job impacts  represent  the net change  in employment  
across  the economy,  which is composed  of positive  impacts  for some  industries  and negative  
impacts  for others.  In 2043,  the Proposed  Regulation  is estimated  to result  in job gains of 
8,047,  primarily in construction,  retail and wholesale,  and services,  and zero jobs foregone.  
(B) Thecreation  of new businesses  or the elimination  of existing  
businesses  within  the state.  
T
he macroeconomic  model  used  in th
is analysis  cannot  directly  estimate the creation  or 
elimination  of businesses.  However,  changes  in jobs and output  for the California  economy  
can be used to understand some  potential impacts.  The overall  jobs and output  impacts  of 
the Proposed  Regulation  are small  relative  to the total California  economy,  representing  
changes  of no greater  than 0.02 percent ; hence , the overall  impact  on creation  and 
elimination  of businesses  is also expected  to be small  relative  to the total California  
economy . However,  impacts  to some  specific  industries  are relatively  larger  than this. The 15industrial  equipment  repair  industry  is estimated to see negative  impacts,  as ZEFs  become a 
greater  portion of the fleet.  This trend  would  suggest  that the number  of businesses  
providing  those  services  may decrease  along  with the reduced demand.
Additionally,  the decreasing  trend  in demand  for propane  and gasoline  has the potential  to 
result  in the elimination  of businesses  downstream  of refineries,  such as propane  wholesalers  
and merchants,  if sustained  over time,  though the overall  retail  and wholesale  sectors  are 
projected  to expand.
(C) The competitive  advantages  or disadvantages  for businesses  
currently  doing  business  within  the state.  
Staff do es not believe the Proposed Regulation would advantage or disadvantage California 
fleets versus out -of-state fleets. The Proposed Regulation would apply equally to all fleets 
operating forklifts in California whether they are California businesses or out -of-state 
businesses. Furthermore, forklifts are not generally transported from one state to another to 
perform work, so staff do not expect that California forklift fleets are competing for work 
with out -of-state forklift fleets. Although the propos ed forklift requirements could make it 
more expensive in the very short term to operate in California (due to the capital needed to 
purchase ZEFs), the Proposed Regulation is projected to result in overall net savings for fleets 
operating within the state.
The rental agencies near the state border could gain a competitive advantage over rental 
agencies out- of-state with limited zero -emission offerings. California rental agencies could 
potentially recapture the business of fleets that have historically rented  forklifts from  
out-of-state rental agencies. 
(D) The increase  or decrease  of investment  in the state.  
Private domestic investment consists of purchases of residential and nonresidential structures 
and of equipment and software by private businesses and nonprofit institutions. It is used as 
a proxy for impacts on investments in California because it provide s an indicator of the future 
productive capacity of the economy.
The relative changes to growth in private investment for the Proposed Regulation are 
estimated  to result in an increase of private investment of about $33 million in 2030, which 
trends towards an increase of $563 million by 2043. Overall, there is a n estimated  cumulative 
increase of about $1.75 billion for 2026 -2043.
(E) The incentives  for innovation in products,  materials,  or processes.  
The Proposed Regulation would provide flexibility to fleets that replace Targeted Class IV 
and V Forklifts with ZEFs ahead of their phase -out deadlines. Forklifts replaced ahead of 
compliance deadlines would provide fleet owners with the ability to reduce compliance 
burden in future years. Furthermore, financial incentive programs are more likely to fund 
compliance actions that are early or over -and-above what is required. Considering these 
reasons, staff believes that some fleets could opt to comply ahead of phase -out deadlines to 16access these incentives as well as to start reaping the operational benefits of zero -emission 
technology.
Staff anticipates growth in industries that manufacture or support ZEFs, including ZEF and 
ZEF-component manufacturers and suppliers, infrastructure installers, electrical powertrain 
technicians, and others. This growth is, in turn, expected to strengthen the ZEF supply chain, 
generate greater technology awareness, and foster a greater ZE market. In addition, because 
the Proposed Regulation would provide a strong signal of California’s continued commitment 
to zero -emission technology, staff believes it woul d spur greater private investment, and 
accelerate technology innovation and market growth.
(F) The  benefits  of the regulations,  including,  but not limited  to, 
benefits  to the health,  safety,  and welfare of California  residents,  worker  
safety,  and the state ’s environment  and quality  of life, among  any other  
benefits  identified  by the agency.  
The Proposed Regulation would improve air quality by reducing statewide NOx, PM2.5, and 
ROG emissions. The Proposed Regulation would also achieve GHG emission reductions 
needed to combat climate change and its impacts. From 2026 to 2043, the Proposed 
Regulation is estimated to result in 18,7 24 tons reduction in N Ox, 2,075 tons reduction in 
PM2.5, 4,973  tons reduction in ROG, and 9.4 MMT reduction of CO 2, relative to  
business -as-usual.
The Proposed Regulation will lead to an estimated 544 fewer cardiopulmonary deaths; 115 
fewer hospital admissions for cardiovascular disease; 148 fewer cases of cardiovascular 
Emergency Department visits; 62 fewer cases of nonfatal acute myocardial infarction; 17 
fewer hospitalizations for respiratory disease; 321 fewer cases of respiratory Emergency 
Department visits; 42 fewer cases of lung cancer incidence; 1295  fewer cases of asthma 
onset; 109,800 fewer cases of asthma symptoms; 80,635 fewer cases of wor k loss days; 272 
fewer hospitalizations for Alzheimer’s disease; and 39 fewer hospitalizations for Parkinson’s 
disease.  These health outcomes result in a total cost savings of $7.5 billion. The avoided 
social cost of carbon range s from about $0.25  to $1 billion over this same timeframe
Although  not quantified,  the Proposed  Regulation  would  also reduce  occupational  exposure  
to carbon  monoxide  (CO),  a pollutant  that can cause  fatigue,  headaches,  confusion,  and 
dizziness,  especially  in indoor  environments  where  forklifts  commonly  operate23. The emission  
reductions  expected  from  the Proposed  Regulation  would  benefit  California  residents  by 
reducing  their exposure  to harmful  air pollutants  associated with adverse  health  impacts.  In 
particular,  individuals  who operate  Class IV and V forklifts,  those  who work  at facilities  where  
said forklifts  operate,  and those  who live within  communities  that are disproportionately  
impacted  by air pollution  would  benefit  most  from  the Proposed  Regulation.
23CARB , Carbon  Monoxide  and Health  (web  link: https://ww2.arb.ca.gov/resources/  
carbon -monoxide -and-health#:~:text=Carbon%20monoxide%20is%20harmful%20because,oxygen%20delivery  
%20to%20the%20brain , last accessed  on August  2023).17The Proposed  Regulation  could  decrease  the occupational  exposure  to air pollution  of forklift  
operators  and other  people  who work  around forklifts  in California.  These  individuals  are 
likely  at higher  risk of developing  cardiovascular  and respiratory  issues  as a result  of forklift  
PM emissions.  Although  CARB  staff cannot  quantify  the potential effect  on occupational  
exposure,  the Proposed  Regulation  is expected  to provide larger  health  benefits  for these  
individuals.
Targeted  Class  IV and Class V Forklifts  are well-suited to transition  to zero-emission  
technology.  As more  fleets  convert  to ZEFs  due to the Proposed  Regulation,  forklift  
manufacturers  would  be expected  to maintain  or possibly  even  increase  their investments  in 
developing  zero-emission  technologies  and expand  their zero-emission  product  lines.  Such  
investments  could  contribute to break -through  technologies  and broader  acceptance  of 
zero-emission  technologies  in off-road vehicle  applications.
The increased use of electric  charging  infrastructure  by off-road electric  vehicles  would  
decrease  the amount  of fossil  fuel consumed  in California,  helping  the State  meet  the goals  
of SB 35024. Furthermore,  SB 350 directs  investor -owned  utilities  (IOU)  to implement  
programs  to accelerate  widespread transportation  electrification,  including  the deployment  
of charging  infrastructure.  SB 350 goals  include  increasing  the sales  of zero-emission  vehicles,  
reducing  air pollutant  emissions  to help meet  air quality  standards,  and reduce  GHGs.  As a 
result  of SB 350, the States’  three  large  IOUs  (PG&E,  SDG&E,  and SCE)  are establishing  or 
have  established  commercial  electricity  rate programs  that reduce  battery  charging  rates  at 
specified times  of the day. Some  publicly -owned  utilities  have  developed  similar  
transportation  electrification rate programs  as the IOUs.  By increasing  the number  of ZEFs  in 
the State,  the Proposed  Regulation  would  support  the utilities  programs  and help meet  
SB 350 goals.
(G) Department  of Finance  Comments  and Responses.  
1. SRIA needs  to identify any changes  in the amount  of operating income 
received  by state  and local agencies . 
DOF  Comment:  The SRIA must  identify  any changes  in the amount  of operating  income  
received  by state  and local  agencies.  The SRIA  estimates  that the impact  on state  personal 
income  will exceed  $1 billion in several  years.  State  income  tax revenue  is typically equal to 
about 4 percent  of state  personal  income,  thus,  a $1 billion change  in income  could cause  
income  tax revenue  to change  by about $40 million. The SRIA should  provide estimates  for 
the regulation’s  expected  impact  on income  tax revenue  in each  year of the analysis.  
Response:  The model  used  to estimate  the macroeconomic  impacts  of the Proposed  
Regulation  on the California  economy  includ es impacts  to personal  income.  Changes  in 
personal  income  in California  may change  the amount  of revenue  the State  of California  
collects  in personal  income  tax. From  2026  to 2043,  the average  change  in California  State  
Personal  Income  and Personal  Income  Tax Revenue  are estimate d at $168.1  million  and $6.7 
million  (2021$),  respectively.  A table  detailing  the estimated  change  in personal  income  and
24https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB35018personal  income  tax revenue  over the regulatory  horizon  can be found  in Chapter  VIII, 
Section  E.2.f of the ISOR . The change  in personal  income  tax is estimated based on a 
statewide  average  tax rate of about four percent.25
2.SRIA needs  to explain the rationale, use a distribution of forklift  lifespans , or 
conduct  a sensitivity  analysis  for assuming  15-year lifespans  for new forklifts 
without  a corresponding distribution of forklift lifespans . 
DOF Comment:  The SRIA must  explain the rationale  of any assumption  material  to the 
impact  estimate. It assumes  that capital  expenditures  on new forklifts will  spike in 2041  as all 
the forklifts purchased  in 2026  reach  the end of their expected  15-year lifespans  and will 
need  to be replaced.  The SRIA should  explain why this is the most  plausible  assumption  for 
the analysis  or use a distribution  of forklift  lifespans  (or possibly  a sensitivity analysis  with 
several  plausible distributions)  that is more  typical  for vehicles.  
Resp onse: The Proposed Regulation, at the time the SRIA was finalized, required retirement 
of existing LSI forklifts from 2026 to 2038 (with exceptions based on lift capacity). CARB staff 
assumed each retired LSI forklift would be replaced with an electric forklift.  CARB staff 
modeled a 15 -year life for each of the electric forklifts purchased under the regulation. The 
15-year life for electric forklifts leads to replacement purchases for each forklift that mirror 
the original regulatory schedule exactly 15 years lat er. For example, all electric forklifts 
purchased in 2026 to comply with the Proposed Regulation are replaced in 2041, etc.  The 
15-year life was based on the age distribution of the electric forklifts reported to CARB in the 
online reporting database, DOORS. Fifteen  years represents the median useful life of 
forklifts, or the age where 50 percent of the electric forklifts appear to be retired from 
service.  
Based on the comments from DOF, CARB staff modeled two additional scenarios where the 
replacement of electric forklifts was spread over a range of years rather than all being 
replaced exactly at 15 years. Under the first scenario, purchases were spread over the 3 -year 
range from age 14  to 16, and under the second scenario, purchases were spread even further 
over an 11 -year range from age of 10 to 20.
If electric forklifts are replaced from age 14 to 16, the peak replacement purchases would 
occur in 2042, and would be 26 percent lower than the previous peak in 2041. If electric 
25The statewide  average  income  tax rate varies  over time.  It averaged  about  four percent  over the period of 
2015 -2022  based  on historical  personal  income  data.  Specifically,  statewide  average  income  tax rate was 
calculated  by dividing  annual  personal  income  tax revenue  projections  obtained from  the May Revision  of the 
California  Governor’s  Proposed  Budget  for fiscal  years  2017 -2018  through  2023 -2024,  which  are available  
through https://ebudget.ca.gov/ , last accessed  October  2023,  and dividing  by total personal  income  provided  
in the California  Economic  Forecast  spreadsheet  prepared  by the California  Department  of Finance  (web  link:
https://dof.ca.gov/wp -content/uploads/sites/352/Forecasting/Economics/Documents/California -Economic-
Forecast -MR-2023 -24.xlsx ); the California  Economic  Forecast  spreadsheet  is also available  through  the 
Department  of Finance’s  Economic Forecasts  webpage  athttps://dof.ca.gov/forecasting/Economics/economic -
forecasts -u-s-and-california/ , last accessed  October  2023.19forklifts are replaced from age 10 to 20, the peak replacement year would not occur until 
2046, and would be 35 percent below the previous 2041 peak replacement purchases.
Ultimately, the total purchases during the period from 2036 to 2050 would vary by less than 
half of one percent . However , peak year costs would be significantly reduced in either of the 
scenarios explored.
The 15 -year life was selected as a typical lifespan for an electric forklift. Realistically, the exact 
behavior and replacement of electric forklifts will depend on use, owner preferences, 
economic conditions, and additional details specific to the forklif t and owner. This analysis 
demonstrates that peak year costs may vary but the overall number of forklifts replaced 
during the period (and therefore overall costs) is consistent across various retirement 
assumptions and modeling.
Business  Report  (Gov. Code,  §§ 11346.5,  subd.  (a)(11); 11346.3,  
subd.  (d)):
In accordance with Government Code  sections  11346.5,  subdivisions  (a)(11)  and 11346.3,  
subdivision  (d), the Executive  Officer  finds  the reporting  requirements of the proposed  
regulatory  action  which  apply  to businesses  are necessary for the health,  safety, and welfare  
of the people  of the State  of California .
Cost Impacts  on Representative  Private Persons  or Businesses  (Gov.  
Code,  § 11346.5,  subd.  (a)(9)):
In de
veloping  this regulatory  proposal,  CARB  staff evaluated  the potential economic  im
pacts  
on representative  private  persons  or businesses.
CARB  staff expects  that there  would  not be direct  costs  to individuals  as a result  of this 
Proposed  Regulation.  Individuals  would  realize  health  benefits,  as described  in the Health  
Benefits  section  of the ISOR , from  statewide,  regional,  and local emission  benefits  due to 
ZEFs  displacing  LSI forklifts.  H
owever,  individuals  could  be impacted  by indirect  costs  and 
savings  realized  by fleet o perators,  rental  agencies,  and manufacturers,  which  are further  
discussed in the Macroeconomic  Impacts  chapter  of the ISOR .
A typical  business  that currently  owns  and/or  operates  Class IV or Class V forklifts  would  incur  
upfront  capital  costs  and on-going  operating  costs  due to the Proposed  Regulation.  These  
costs  would  include,  as applicable,  the p
urchase  cost of ZEFs,  ZEF batteries,  and ZEF 
chargers;  costs  associated  with installing chargers  and/or  upgrading  facility -side electrical  or 
fueling  infrastructure;  electricity  or fuel costs;  maintenance  costs;  finance  charges;  and taxes.  
In addition,  a typical  business  would  also incur  compliance  costs,  such as recordkeeping  and 
reporting  costs.  A typical  business  would  also be expected  to realize  cost savings  that offset  
costs;  such savings  would  include  reduced f
uel and maintenance  costs  and potential  LCFS  
credit  revenue.20Effect on Small  Business  (Cal. Code  Regs.,  tit. 1, § 4, subds.  (a) and (b)):
The Executive  Officer  has also determined under  California  Code  of Regulations,  title 1, 
section  4, that the proposed  regulatory  action  would  affect  small  businesses . The 
methodology  and full details  for estimating  the cost impact  to an example  small  business  is 
provided  in Chapter  VIII of the ISOR.
Consideration  of Alternatives  (Gov.  Code,  § 11346.5,  subd.  (a)(13)):
Before  taking  final action  on the proposed  regulatory  action, the Board  must  determine  that 
no reasonable  alternative  considered by the Board,  or that has otherwise  been  identified  and 
brought  to the attention  of the Board  would  be more  effective  in carrying  out the purpose 
for which  the action  is proposed,  would  be as effective  and less burdensome  to affected  
private  persons  than the proposed  action, or would  be more  cost-effective  to affected  
private  persons  and equally  effective  in implementing  the statutory  policy  or other  provisions  
of law. As explained in the accompanying  Chapter  IX of the ISOR,  the Proposed  Regulation  is 
the most  effective  and least  burdensome  means  of achieving the purposes  of the proposal.
The Executive  Officer  analyzed  several  alternatives  to the Proposed  Regulation  and 
summarized  the findings  of this analysis  in Chapter  IX of the ISOR,  and the rationale  behind 
rejecting  them  in favor  of the Proposed  Regulation.  The following  is a brief summary  of the 
major  alternatives  proposed  and the rationale  for rejecting  such major  alternatives .
Alternative  1 (more  stringent)  would  accelerate the phase -out of both  Targeted  Class  IV 
Forklifts  and Targeted  Class  V Forklifts.  As discussed in the Summary  of Proposed  
Rulemaking,  the Proposed  Regulation  would  phase  out Targeted  Class  IV Forklifts  between  
2028  and 2038  and Targeted  Class  V Forklifts  between  2030  and 2038.  Alternative  1 would  
phase  out both  Targeted  Class  IV and Class  V Forklifts  between  2028  and 2032.
Although Alternative 1 would achieve greater emission benefits and greater cumulative net 
savings due to the accelerated turnover of Targeted Class IV and Class V Forklifts to ZEFs, it 
was rejected for the following reasons:
·The turnover rate of Targeted Forklifts under Alternative 1 would create a significantly 
greater cost burden for fleets during the first five years of the regulation. While using 
ZEFs is expected to result in cost savings over time, the upfront cost of Alt ernative 1 
could be too challenging to overcome for fleets that are more constrained with 
respect to available capital. Alternative 1 has an estimated cumulative net cost of 
approximately $593 million from 2026 through 2030 whereas the Proposed Regulation 
has an estimated cumulative net savings of approximately $116 million over that same 
period (a difference of about $709 million). From 2026 to 2043, the estimated upfront 
costs (forklift purchases, sales tax, and infrastructure installation) for Alternativ e 1 are 
$5.5 billion, whereas the estimated upfront costs over the same period for the 
Proposed Regulation are $5.1 billion. From 2026 to 2043, the present value26upfront 
costs for Alternative 1 and the Proposed Regulation are approximately $3.9 billion and 
26Present  value  accounts  for the time value  of money.  For the purpose  of this analysis,  the present  value  is 
based  on a five percent  rate of return.21$2.7 billion, respectively. Consequently, the present value upfront costs of Alternative 
1 are roughly $1.2 billion (or 44 percent) higher than the Proposed Regulation.
·In addition, Alternative 1’s turnover rate could also pose a challenge for manufacturers 
to build sufficient numbers of ZEF products in the proposed timeframe. Under the 
baseline scenario, an estimated 9,250 ZEF and 18,470 LSI Forklift purchases (due to 
natural turnover) are expected during the first three years of the phase -out schedule. 
Under Alternative 1, in addition to the estimated 9,250 ZEF purchases needed to 
maintain the existing ZEF baseline population, 52,280 ZEFs would be purchased within 
the fi rst three years of the phase -out schedule. By contrast, under the Proposed 
Regulation, 18,810 ZEFs (surplus to baseline) would be purchased during the same 
timeframe. Consequently, during the first three years of the phase -out schedule, 
Alternative 1 would  require added purchases of almost three times more ZEFs than 
the Proposed Regulation and five times more ZEFs than the baseline scenario.
·Furthermore, based on stakeholder feedback, manufacturer supply chain delays are 
responsible for current forklift delivery delays of an additional one to one -and-a-half 
years, relative to pre -pandemic delivery timelines. Especially for Alternative 1, which  
has a more -accelerated turnover rate, the anticipated growth in demand for certain 
components used in ZEFs could exacerbate delays in manufacturing and supply chain 
disruptions, which could further impact delivery dates of ZEFs. Difficulty in procuring 
necessary components could also place manufacturers in difficult competitive and 
financial positions in market segments where they could be required to redesign their 
products and retool their operations earlier than planned to accommodate parts that 
are ava ilable. 
Alternative 2 (less stringent) would only apply to Targeted Class IV and Class V Forklifts with 
a lift capacity of 8,000 pounds or less. That is, unlike the Proposed Regulation, Alternative 2 
would not require the phase -out of Targeted Class IV and Class V  Forklifts with a lift capacity 
greater than 8, 000 pounds. The phase -out schedules for Alternative 2 would be the same as 
those in the Proposed Regulation for both forklift classes.
The projected upfront cost for Alternative 2 is lower than the Proposed Regulation, and its 
benefit -cost ratio is higher than for the Proposed Regulation (2.72 versus 2.26).  However, 
Alternative 2 would also result in lower NOx, PM2.5, ROG, and CO 2 emission benefits and 
fewer ZEFs deployed. Although CARB's 2016 SIP commitment for ROG reductions of 0.2  
tons per day  (TPD) by 2031 would be met through Alternative 2, the commitment for NOx 
reductions of 2 TPD by 2031 would not be met. Alternative 2 would obtain  only 0.81 TPD 
NOx by 2031.
The deployment of zero -emission vehicles and equipment is a key component of California’s 
long-term strategy to meet its aggressive air quality, climate, and zero -emission goals. 
Alternative 2 was rejected because it would not be as effective as the Propos ed Regulation at 
improving air quality and protecting public health, combating climate change, and 
accelerating the adoption of ZE technology.22State Implementation Plan Revision 
If adopted  by CARB,  CARB  plans  to submit  the proposed  regulatory  action  to the United  
States  Environmental  Protection  Agency  (U.S.  EPA) for approval  as a revision  to the California  
SIP required  by the federal  CAA. The adopted  regulatory  action  would  be submitted  as a SIP 
revision  because  it adopts regulations  intended  to reduce  emissions  of air pollutants  in order  
to attain  and maintain  the NAAQS  promulgated  by U.S. EPA pursuant  to the CAA.
Environmental Analysis
CARB,  as the lead agency  for the Proposed  Regulation , has prepared  a draft  environmental  
impact  analysis  (EIA) under  its certified  regulatory  program  (CCR, title 17, §§ 60000  through 
60008)  to comply  with the requirements  of the California  Environmental  Quality  Act (CEQA)  
(Public  Res. Code  § 21080.5).  The EIA concluded  implementation of the Proposed  Regulation  
could  result  in: beneficial  impacts  to air quality  (long -term  operational -related),  greenhouse  
gas emission  (short -term  construction  and long-term  operational- related) ; less than significant  
impacts  to energy  (short -term  construction -related  and long-term  operational- related ), 
mineral  resources,  population  and housing,  public  services,  recreation,  and wildfire;  and 
potentially  significant  [indirect/secondary]  adverse  impacts  to aesthetics,  agriculture  and 
forestry  resources,  air quality  (short -term  construction -related),  odors,  biological  resources,  
cultural  resources,  geology  and soils,  hazards  and hazardous  materials, hydrology  and water  
quality, land use planning,  noise  and vibration,  transportation,  tribal  cultural  resources,  and 
utilities  and service  systems . The Draft  EIA is included  as Appendix  C the ISOR.  Written  
comments on the Draft  EIA will be accepted  during  a 45-day public  review  period  starting  on 
October  20, 2023,  and ending on December  4, 2023.
Special Accommodation Request
Consistent with California  Government Code  section  7296.2,  special  accommodation  or 
language  needs  may be provided  for any of the following:
·An interpreter  to be available  at the hearing;
·Documents  made  available  in an alternate  format  or another language;  and
·A disability -related  reasonable  accommodation.
To request these  special  accommodations  or language  needs,  please  contact  the Clerks’  
Office  atcotb@arb.ca.gov or (916)  322-5594  as soon  as possible,  but no later than ten 
business  days before the scheduled  Board  hearing.  TTY/TDD/Speech  to Speech  users  may 
dial 711 for the California  Relay  Service.
Consecuente  con la sección  7296.2  del Código  de Gobierno  de California,  una acomodación  
especial  o necesidades  lingü? sticas  pueden  ser suministradas  para cualquiera  de los 
siguientes:
·Un intérprete  que esté disponible  en la audiencia;
·Documentos  disponibles  en un formato  alterno  u otro idioma;  y
·Una acomodación  razonable  relacionados  con una incapacidad.23Para solicitar  estas  comodidades  especiales  o necesidades  de otro idioma,  por favor  llame  a 
la oficina  del Consejo  alcotb@arb.ca.gov o (916)  322-5594  lo m?s pronto  posible,  pero  no 
menos  de 10 d?as de trabajo  antes  del d?a programado  para la audiencia  del Consejo.  
TTY/TDD/Personas que necesiten  este servicio  pueden  marcar  el 711 para el Servicio  de 
Retransmisión  de Mensajes  de California.
Agency Contact Persons
Inquiries  concerning the substance  of the proposed  regulatory  action  may be directed  to the 
agency  representative  Keith  Roderick,  Air Resources  Engineer,  Staff Lead , Advanced  
Emission  Control  Strategies  Section,  at 279-208-7768  or Lori Berard, Air Pollution  Specialist,  
Cost Analysis  Lead,  Advanced  Emission  Control  Strategies  Section,  at 951-542-3083.
Availability of Documents
CARB  staff has prepared  an ISOR  for the proposed  regulatory  action,  which  includes  a 
summary  of the economic  and environmental  impacts  of the proposal. The report  is entitled:  
Public  Hearing  to Consider  the Proposed  Zero-Emission  Forklift  Regulation
Copies  of the ISOR  and the full text of the proposed  regulatory  language,  [in underline  and 
strikeout  format  to allow  for comparison with the existing  regulations  (if applicable) , may be 
accessed  on CARB’s  website  listed  below,  on October  17, 2023 . Please  contact  Bradley  
Bechtold : Regulations  Coordinator,  at Bradley.Bechtold @arb.ca.gov  or (279) 208-7266  if you 
need  physical  copies  of the documents.  Because  of current  travel,  facility,  and staffing  
restrictions,  the California  Air Resources  Board’s  offices  have  limited  public  access.  Pursuant  
to Government Code  section  11346.5,  subdivision  (b), upon  request  to the aforementioned  
Regulations  Coordinator,  physical  copies  would  be obtained  from  the Public  Information 
Office,  California  Air Resources  Board,  1001  I Street, Visitors  and Environmental  Services  
Center,  First Floor,  Sacramento,  California,  95814.
Further,  the agency  representative  to whom  nonsubstantive  inquiries  concerning  the 
proposed  administrative action  may be directed  is Bradley  Bechtold , Regulations  
Coordinator,  (279) 208-7266.  The Board  staff has compiled  a record  for this rulemaking 
action, which  includes  all the information  upon  which  the proposal  is based.  This material  is 
available  for inspection  upon  request to the contact  persons.
Hearing Procedures
The public  hearing will be conducted  in accordance with the California  Administrative  
Procedure  Act, Government  Code,  title 2, division  3, part 1, chapter  3.5 (commencing  with 
section  11340).
Following  the public  hearing,  the Board  may take action  to approve  for adoption  the 
regulatory  language  as originally  proposed,  or with non-substantial  or grammatical  
modifications.  The Board  may also approve for adoption  the proposed  regulatory  language  
with other  modifications  if the text as modified  is sufficiently  related  to the originally24proposed  text that the public  was adequately placed  on notice  and that the regulatory  
language  as modified  could  result  from  the proposed  regulatory  action. If this occurs,  the full 
regulatory  text, with the modifications  clearly  indicated,  will be made  available  to the public,  
for written  comment,  at least  15-days before final adoption.
The public  may request  a copy  of the modified  regulatory  text from  CARB’s  Public  
Information  Office,  Air Resources  Board,  1001  I Street,  Visitors  and Environmental  Services  
Center,  First Floor,  Sacramento,  California,  95814.
Final Statement of Reasons Availability
Upon  its completion,  the Final  Statement of Reasons  (FSOR)  will be available,  and copies  may 
be requested from  the agency  contact  persons  in this notice  or may be accessed on CARB’s  
website  listed  below.
Internet Access
This notice, the ISOR  and all subsequent  regulatory  documents,  including  the FSOR, when  
completed,  are available  on CARB’s  website  for this rulemaking at
https://ww2.arb.ca.gov/rulemaking/2023/zeforkliftsregulation
California  Air Resources  Board
_________________________________
Steven  Cliff
Executive  Officer
Date: October  3, 2023
The energy  challenge  facing  California  is real. Every  Californian  needs  to take immediate  
action  to reduce  energy  consumption.  For a list of simple  ways  you can reduce  demand  and 
cut your energy  costs,  seeCARB’s  website (www.arb.ca.gov ).